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Post Market Surveillance (PMS) Report

 At RAPS, we understand the critical importance of Post Market Surveillance (PMS) for medical device manufacturers. Regardless of the device's classification, PMS is not just a regulatory requirement—it's an essential component of ongoing product safety, performance monitoring, and risk management. 

Why PMS Matters

 

Under the EU Medical Device Regulation (MDR) 2017/745, manufacturers are required to implement a robust PMS system aligned with the device's risk class and type. The conformity assessment procedures outlined in Annexes IX to XI mandate that this system be proportionate to the level of risk, with specific requirements varying by classification.

Manufacturers must establish a PMS Plan (Article 84), which forms part of the technical documentation. This plan must demonstrate compliance with the 2017/745 requirements and detail how post-market data will be systematically collected, analyzed, and used. Annex III further defines the required structure and content of the PMS strategy.

 

What the Regulation Says

According to Article 2(60) of the MDR, PMS is defined as a proactive and systematic process carried out by manufacturers in collaboration with other economic operators—such as importers, distributors, and authorized representatives. This process supports timely Corrective and Preventive Actions (CAPA) based on real-world data regarding the performance and safety of the medical device.

 


 

Enhancing Patient Safety

The PMS system plays a pivotal role in identifying potential issues related to design, manufacturing, or clinical use. By continuously monitoring device performance throughout its entire lifecycle, manufacturers can ensure:

  • Early detection of risks or failures
     
  • Up-to-date risk-benefit evaluations
     
  • Prompt implementation of necessary improvements
     

Manufacturers are also expected to monitor similar devices on the market, including those from competitors, to maintain a comprehensive view of safety trends and performance benchmarks.

 

PMS Report Template

Save time and ensure compliance with our ready-to-use Microsoft Word PMS Report Template, crafted by regulatory experts. These templates meet the standards of EN ISO 13485:2016 (Section 8.2.1) and align with Meddev NB-MED/2.12/Rec.1 guidelines, making them ideal for demonstrating regulatory compliance during audits or reviews.

 

PMS Report for Class I Medical Devices

Even for Class I medical devices—including subclasses Is (sterile), Im (measuring), and Ir (reusable surgical instruments)—manufacturers are required to develop and maintain a Post-Market Surveillance (PMS) Report. This report must provide a concise summary of findings, conclusions, and actions taken based on post-market data.

The PMS report must:

  • Summarize relevant findings from ongoing surveillance
     
  • Justify corrective and preventive measures taken
     
  • Be updated regularly in line with new data and insights

 

Supporting Your PMS Responsibilities

At RAPS, we offer expert resources to help Class I device manufacturers stay compliant and proactive. Our solutions are designed to:

  • Guide manufacturers in creating and implementing a compliant PMS Plan
     
  • Support the full PMS process, from data collection to reporting
     
  • Provide a structured PMS procedure and customizable PMS Report template
     
  • Identify Post-Market Clinical Follow-up (PMCF) needs emerging from PMS data
     
  • Help interpret PMS findings to inform ongoing device safety and performance
     

Building an Effective PMS Team

Manufacturers are advised to assemble a cross-functional PMS team, involving representatives from regulatory, quality, clinical, and technical departments. This team is responsible for coordinating surveillance activities and ensuring compliance with MDR Article 85 requirements for Class I devices.

Collaborating with regulatory experts and consultants—like those at RAPS—can also enhance your PMS strategy. We help you:

  • Define your target patient or user group
     
  • Predict and mitigate risks more effectively
     
  • Design responsive monitoring programs for new technologies
     

Early identification of issues through a proactive PMS approach ensures not only regulatory compliance, but also improves patient safety and builds market confidence in your product.

 

Features of a Good Post-Market Surveillance (PMS) Report

An effective Post-Market Surveillance (PMS) Report goes beyond regulatory compliance—it forms the foundation of a manufacturer’s ongoing safety, performance, and risk evaluation for medical devices.

When developing a PMS Report, manufacturers must evaluate:

  • The technology of the device
     
  • Its position in the market
     
  • Comparable devices already in use
     
  • The target patient population
     
  • The manufacturer’s capabilities to monitor and act on field data
     

For newer technologies or emerging manufacturers, the complexity of real-world device use and patient variability can pose challenges—making a robust PMS strategy even more essential.

 

Key Elements of a High-Quality PMS Report

Aligned with EU MDR 2017/745, particularly Article 2(60), a comprehensive PMS Report should include:

  • Analysis of Current Market Data: For low-risk devices with long usage history, real-world market data may suffice to meet clinical evaluation needs.
     
  • Clinical Data Review: Reference to peer-reviewed literature supporting the device’s safety and performance.
     
  • Proactive Risk Detection: Systems for identifying unanticipated hazards post-launch through increased monitoring and trend analysis.
     
  • Post-Market Clinical Follow-Up (PMCF): Where needed, implementation of a PMCF Plan per Annex XIV Part B, or justification if PMCF is not applicable.
     
  • Performance Evaluation Methodologies: Clearly defined methods to reliably evaluate device performance and benchmark against similar devices.
     
  • Risk-Benefit Monitoring: Use of measurable indicators and threshold values to continuously assess risk-benefit ratios, as outlined in Annex I Section 3.
     
  • Trend Reporting Protocols: Mechanisms to identify statistically significant changes in incident trends in line with Article 88.
     
  • Communication Processes: Established protocols for notifying competent authorities, notified bodies, distributors, and end users as needed.
     
  • Regulatory Compliance Procedures: Documentation of compliance with Articles 83, 84, and 86, detailing responsibilities, timing, and reporting channels.
     
  • Corrective and Preventive Action (CAPA): Defined procedures for initiating appropriate actions in response to findings.
     
  • Device Traceability: Tools to trace devices that require recall, replacement, or repair.

 

MDR and ISO 14971: A Clearer Framework

Compared to the previous Medical Device Directive (MDD), MDR provides clearer alignment between PMS requirements and ISO 14971 (Clause 9) on risk management. Under MDR, PMS is a general obligation for all device manufacturers, and must be built into the organization’s Quality Management System.

Reactive vs. Proactive PMS Approaches

  • Reactive PMS involves data collection after incidents occur—such as complaints or adverse events. This passive approach is necessary but limited.
     
  • Proactive PMS anticipates potential risks by gathering real-world data from clinical use, user feedback, and market analysis. This enables early intervention and improves long-term device safety and performance.
     

Integration with ISO 13485

A strong PMS system must be integrated with the manufacturer’s ISO 13485-compliant Quality Management System. It should:

  • Monitor quality, safety, and performance data throughout the device lifecycle
     
  • Link findings directly to the CAPA system
     
  • Support continuous improvement and regulatory readiness

Post-Market Surveillance: A Risk-Based, Proactive Requiremen

 Under ISO 14971 Clause 9, post-production monitoring must be proportionate to the level of risk associated with a medical device, based on its intended use. This principle is now more clearly defined in the EU Medical Device Regulation (MDR) 2017/745, which designates Post-Market Surveillance (PMS) as a general obligation for all manufacturers (Article 2(60)). 

A Systematic, Proactive Approach Under MDR

 

The MDR mandates that manufacturers proactively update and maintain their PMS systems in a comprehensive and systematic way. These activities must be managed by a designated Person Responsible for Regulatory Compliance (PRRC), as outlined in Article 15. This role ensures that the manufacturer’s PMS processes are not only compliant, but also robust and continuously improving.

Through a well-structured PMS system, manufacturers can:

  • Implement interactive Corrective and Preventive Actions (CAPA) proportionate to the device's risk class
     
  • Regularly update clinical evaluation documentation in light of new post-market data
     
  • Detect and respond to emerging risks swiftly, improving device safety over its lifecycle

 

Integration with ISO 13485 Quality Systems

Since ISO 13485 applies to all medical devices, PMS strategies must be embedded within the Quality Management System (QMS). This integration ensures that post-market surveillance is not a standalone activity, but a continuous feedback loop tied to quality outputs and risk management.

Key QMS integrations include:

  • Vigilance as a QMS output: Post-market clinical data collection and reporting of serious incidents should be systematically documented as part of the device’s technical file.
     
  • PMS-driven vigilance systems: A structured vigilance system allows for the identification of unreported or emerging adverse events.
     
  • Regulatory reporting: Significant device-related incidents must be promptly reported to the relevant competent authorities, helping prevent recurrence of events that could result in death or serious health deterioration.
     

Risk-Proportional Surveillance

It is essential that PMS activities are scaled appropriately to the risk level of the device and its intended application. For low-risk devices, simplified surveillance may be sufficient, while higher-risk or novel technologies demand more rigorous post-market monitoring and data analysis.

 

In today’s evolving regulatory landscape, a well-designed Post-Market Surveillance system is not just a compliance requirement—it's a strategic asset. By aligning PMS activities with ISO 13485 and EU MDR, manufacturers can enhance patient safety, drive continuous improvement, and maintain trust in their medical devices. At RAPS, we provide the tools, templates, and expertise to help you build a proactive, risk-based PMS system that supports regulatory compliance and long-term product success.

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